OECD: Consultation Document on Transfer Pricing Issues for Bauxite
On 10 May 2023 the OECD published a consultation document with the title Determining the price of minerals: A Transfer Pricing Framework – Schedule A: Bauxite. This document follows on from the OECD’s toolkit outlining a transfer pricing
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OECD: Progress Report to G7 Finance Ministers on Tax Cooperation
On 11 May 2023 the OECD published a progress report on tax cooperation for the G7 Finance Ministers and central bank governors. A report on these issues had been produced in 2022 and the G7 Finance Ministers asked the OECD to continue its work on
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Brazil publishes law extending certain CFC benefits
On 13 April 2023, Law No. 14.547 transposing Provisional Measure 1148/2022 into law was published in the Brazilian Official Gazette, which extends certain benefits in regard to the controlled foreign company (CFC) rules under Law 12,973/14. Under
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Singapore: IRAS updates e-Tax Guide on the general anti-avoidance provision and its application
On 31 Mar 2023, the Inland Revenue Authority of Singapore (IRAS) published the second edition of its e-Tax Guide concerning The General Anti-Avoidance Provision and its Application. The updated guide includes the following main purposes: First,
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Australia releases exposure draft bill on new thin cap rules
On 16 March 2023, the Australian Treasury issued the Exposure Draft on the earnings before interest, taxes, depreciation, and amortization interest limitation rules (EBITDA). Consultation closes on 13 April 2023. The proposal to change the
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OECD Tax Talk Outlines Latest Developments
On 27 February 2023 the OECD gave an update of recent developments in their tax work. G20 Chair’s summary The G20 Chair’s summary following the meeting of G20 finance ministers and central bank governors confirmed that the G20 remains
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OECD Report to the February 2023 Meeting of G20 Finance Ministers
On 24 February 2023 the OECD published its report to the February 2023 meeting of the G20 Finance Ministers and Central Bank Governors. Inclusive Framework The report notes that the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework)
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Czech Republic revises Non-Cooperative jurisdictions list for CFC Rules
On 24 February 2023, the Czech Republic released Financial Bulletin No. 3/2023, that announced the non-cooperative jurisdictions list for the Czech Republic's controlled foreign company (CFC) regulations. The list has been updated in accordance with
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UK: Research on Taxpayer Experience of the Profit Diversion Compliance Facility
On 7 February 2023 HMRC published the results of research commissioned in order to understand taxpayers’ experience of the Profit Diversion Compliance Facility (PDCF) and Diverted Profits enquiry process. The research was conducted through
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OECD: Technical Guidance for Implementation of the Global Minimum Tax
On 2 February 2023 the Inclusive Framework released technical guidance on implementation by governments of the global minimum tax. The Agreed Administrative Guidance for the Pillar Two GloBE Rules aims to ensure co-ordinated outcomes and greater tax
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OECD: Manual on Multilateral Mutual Agreement Procedures and APAs
On 1 February 2023 the OECD released the Manual on the Handling of Multilateral Mutual Agreement Procedures (MAPs) and Advance Pricing Arrangements (APAs) (the MoMA). Multilateral MAPs and APAs can offer greater tax certainty to both taxpayers
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OECD: Public comments received on the design elements of Amount B under Pillar One
On 30 January 2023 the OECD published the comments received on the design elements of Amount B under Pillar One relating to the simplification of transfer pricing rules. Comments were received from more than sixty businesses, institutes, NGOs and
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OECD: Comments received on Draft MLC under Amount A of Pillar One
On 24 January 2023 the OECD published the responses received to the public consultation on the Draft Multilateral Convention (MLC) Provisions on Digital Services Taxes (DSTs) and other Relevant Similar Measures under Amount A of Pillar One. The
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OECD: Revised Methodology for the BEPS Action 14 Peer Reviews
On 24 January 2023 the OECD’s Inclusive Framework on base erosion and profit shifting (BEPS) agreed a new assessment methodology for continuing the peer review process under BEPS action 14 to improve tax dispute resolution mechanisms. The
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OECD: Revenue Impact of International Tax Reform
During a live webinar on 18 January 2023 the OECD presented the findings of a new analysis of the estimated impact on tax revenue of the implementation of the two-pillar international tax reform. The new analysis carried out by the OECD indicates
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Belgium amends guidance on interest deduction rule
On 12 January 2023, Belgium issued Circular 2023/C/8, which provides instructions on the application of the 30% of EBITDA interest deduction limitation starting from 1 January 2019, in line with the EU Anti-Tax Avoidance Directive (ATAD). A summary
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Singapore: IRAS releases guidance on tax treatment of gains or losses from the sale of foreign assets
On 8 December 2023, the Inland Revenue Authority of Singapore (IRAS) released an updated e-tax guide on the tax treatment of gains or losses from the sale of foreign assets under the recently introduced Section 10(L) of the Income Tax Act (ITA).
See MoreIASB: Proposed Amendments to IAS 12 Arising from Pillar Two Rules
In January 2023 the International Accounting Standards Board (IASB) issued an Exposure Draft with proposed amendments to IAS 12 (Income Taxes). The amendments relate to tax and accounting implications of the implementation of the global minimum
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